NY Times v. Sullivan

(1964)

NY Times v. Sullivan

(1964)

Basic Facts

New York Times published a paper stating that MLK Jr.'s arrest was part of a ploy, devised by the Montgomery police, to destroy his efforts to allow blacks to vote. Montgomery city commissioner L.B Sullivan filed a lawsuit claiming that the allegations harmed/affected him personally. Sullivan did not have to prove that he was harmed, and since the ad contained false evidence a defense claiming the ad was truthful was unavailable. Sullivan received a $500,000 judgement.

Question

Did Alabama's libel law, by not requiring Sullivan to prove that an advertisement personally harmed him and dismissing the same as untruthful due to factual errors, unconstitutionally infringe on the First Amendment's freedom of speech and freedom of press protections?

Constitutional Reference

1st Amendment- Freedom of Press/Freedom of Speech

Conclusion (7-2 Supreme Court Vote)

Court held that the 1st Amendment protected all publications made, including false ones, unless they are made with actual malice (knowledge that they are false and still published with intent to harm someone). Sullivan's case collapsed due to hard evidence to prove against the NY Times publication.

Precedent

This court case established the actual malice standard, which requires the plaintiff to prove that publisher was aware of the false statements and published it anyway. This places a high burden of proof on the plaintiff and makes it hard to argue against the publisher's statements.

Previously, news organizations that desired to run these stories were often hesitant due to fear that they would be dragged into a liability issue. After this case ruled in favor of the press, this opened up a lot of opportunity for news sources to print stories about civil rights cases in the South.

Significance Today

Today, our understanding of freedom of the press comes in large part from the Sullivan case. The case's principles remain unchallenged, and with the rise of the Internet allowing pretty much anyone to be a worldwide publisher, people are capable of calling public officials instantly to account for their actions, and also of ruining reputations without restrictions or censorship from the government.

Ex. people being able to publicly criticize the government and policies that they don't agree with (such as legalization of marijuana or gun laws), or even running candidates (such as the major hate surrounding Donald Trump in the 2016 election).

Future Relevance

The First Amendment is guaranteed to us as an unalienable right allowing freedom of press to continue functioning without many restrictions as it does so today. I do not see this freedom being taken away from the people in the near future as this would constitute as a great infringement of people's rights. Therefore, as technology continues to develop at an exponential rate and communication nationally and globally becomes an even easier task, people will be able to properly express their opinions about governmental issues surrounding them and have better chances at making a change in what concerns them.